M E M O R A N D U M

To: File

From: Idalia Pérez , EPA Region IX, Air Rulemaking Office

Date: July 22 , 2013 Concerning: EPA Proposed Rule to Approve San Joaquin Valley Contingency Measure SIP

Revision, Fine Particulate Matter (PM2.5)

The 2013 Annual Demonstration Report and associated electronic Data Sheet 1 include the data needed to calculate projected emission reductions from incentive funds in 2015. In order to determine the projected emission reductions from On

- Road Vehicle Replace ment projects funded by Proposition 1B: Goods Movement Emission Reduction Program 2 and Off

- Road Vehicle Replacement projects funded by the Carl Moyer Program, 3 we analyzed the Data Sheet provided by the District as follows

.

From the Data sheet, we identified projects in these two categories that have a “Project Life” that ends on or after January 1, 2016 and thus will be active and achieving reductions through at least

the end of 2015.

There are 1243 Prop 1B and 675 Moyer pr ojects that fit this criterion

. 4 We identified each of

the se projects by its unique “Project Identification” code, as well as the necessary information to

determine its t ons p er d ay of emission reductions

. S ee “Prop 1B

- On

- Road Vehicle Replacement project s achieving emission reductions through 2015.pdf” and “Carl Moyer Program

- Off

- Road Vehicle Replacement projects achieving emission reductions through 2015.pdf” . For each of the identified projects, we determined the “Project Life” in days by multiplying the given “Project Life” in years by 365. We divided the “NO

x Lifetime Reduced Adjusted Percent Operation (tons)” and the “PM Lifetime Reduced Adjusted Percent Operation (tons)” presented in the Data

S heet for each project by its calculated “Project Life” in days to determine the tons per day of

NO

x and PM emissions reduced, respectively, for each project. Finally, w e added the tons per day reduction of NO

x and PM for every project in the two project categories mentioned above

. Based on these calculations, we determined that the projected 2015 emission reductions obtained from Prop 1B On

- Road Truck replacements are 3.78 tpd of NO

x and 0.15 tpd of PM

, and the projected 2015 emission reductions obtained from Moyer Off

- Road Vehicle Replacement are

1 http://www.valleyair.org/MOP/docs/069610ProjectDataforPublicUNLOCKED.xlsx

2 In the Data Sheet, these projects are categorized as: Component: On

- Road Prop 1B; Component Op tion: Vehicle Replacement and Vehicle Replacement 2 for 1; Applicable Guideline: Prop 1B 2008 and Prop 1B 2010.

3 In the Data Sheet, these projects are categorized as: Component: Off

- Road; Component Option: Vehicle Replacement; Applicable Guideline: Carl M oyer 2011.

4 Of the 1243 identified Prop 1B projects, 849 have a “Project Life” ending after December 31, 2016 and will therefore continue to achieve emission reductions through at least the end of 2016. All of the 675 identified Carl Moyer Projects have a “Project Life” ending on or after January 1, 2021 and will therefore continue to achieve emission reductions through at least the end of 2020. See “Prop 1B

- On

- Road Vehicle Replacement projects achieving emission reductions through 2015.pdf” and “Carl Moyer Program

- Off

- Road Vehicle Replacement projects achieving emission reductions through 2015.pdf.”1.23 tpd of NO

x and 0.06 tpd of PM. We carried out this same calculation for the Prop 1B

projects that have a “Project Life” ending after December 31, 2016 and identified 8 53 such projects which, collectively, are projected to achieve 2.35 tpd of NO

x reductions and 0

. 09 tpd of

PM reductions in 2016

. Below we include a sample calculation.

Sample Calculation

Project Identification : P

- 0541 Component: On

- Road Prop 1B Component Option: Vehicle Replacement Project Life (years): 5 Applicable Guideline: Prop 1B 2008

NO

x Lifetime Reduced Adjusted Percent Operation (tons): 4 .62 PM Lifetime Reduced Adjusted Percent Operation (tons): 0.2 8

Sample Calculation of Project Life in days Project Life (days) x 365 (days/year) 5 (years) x 365 (days/year) = 1825 days

Sample Calculation of NO

x Emission Reductions in tons per day

NO

x Lifetime Reduced Adjusted Percent Operation (tons) / Lifetime (days)

4.62 (tons) / 1825 (days) = 2. 53 x 10 - 3 tpd

Sample Calculation of PM Emission Reductions in tons per day

PM Lifetime Reduced Adjusted Percent Operation (tons) / Lifetime (days)

0.2 8 (tons) / 1825 (days) = 1.54 x 10 - 4 tpd